IBFD Journal Features Insight from MUC Professional on Corresponding Adjustments in Indonesia

JAKARTA. Indonesia's commitment to implementing Base Erosion and Profit Shifting (BEPS) Action 13 in accordance with international standards has drawn the attention of professionals at MUC Consulting.

In her article titled “Corresponding Adjustment on Domestic Transfer Pricing Assessment in Indonesia,” Meiliana, Transfer Pricing Manager at MUC Consulting, argues that domestic related-party transactions carry the potential risk of double taxation.

Published in the Journal of the International Bureau of Fiscal Documentation (IBFD), the article explains that the risk of double taxation primarily arises when transfer pricing adjustments are made without a sufficient corresponding adjustment mechanism.

In fact, Minister of Finance Regulation (PMK) Number 172 of 2023 has already introduced the concept of domestic corresponding adjustments in Indonesia.

For taxpayers, this policy facilitates profit allocation among entities, reduces the risk of double taxation, and supports a more proportionate distribution of income.

For the tax authority, the mechanism offers a more efficient alternative for dispute resolution. However, according to Meiliana, there are various challenges and limitations in implementing this policy effectively.

As additional information, the article published on 29 September 2025 was co-authored by Maria R.U.D. Tambunan, a lecturer at the Faculty of Fiscal Administration, University of Indonesia (FIA UI).

IBFD (International Bureau of Fiscal Documentation) is an independent, non-profit global institution focused on international tax research. It is widely recognized as a trusted source for high-quality research and analysis by tax professionals worldwide. (ASP/KEN)